ML20234F143

Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $100,000 from Insp on 870921-1026.Violations Noted:Activities Affecting Quality Not Prescribed by Instructions or Procedures Appropriate to Circumstances

ML20234F143
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	01/04/1988
From:	Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20234F048	List: ML20234F044 ML20234F143
References
50-295-87-32, 50-304-87-33, EA-87-211, NUDOCS 8801110352
Download: ML20234F143 (4)

Text

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NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY Commonwealth Edison Company Docket Nos. 50-295; 50-304 Zion Generating Station Licenses No. OPR-39; DPP-48 Units 1 and 2 EA 87-211 As a result Of an NRC inspection conducted during the period September 21 through October 26, 1997; violations of NRC requirements were identified.

In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1987), the Nuclear Regulatory Commission proposes to impose a civil penalty pursuant to Section 234 of the Atomic Energy Act of 1954, as amended (Act), 42 U.S.C. 2282, and 10 CFR 2.205.

The particular violations and associated civil penalty are set forth below:

A. 10 CFR Part 50, Appendix B, Criterion V, as implemented by Commonwealth Edison Company's Quality Assurance Topical Report, CE-1-A, requires, in part, that activities affecting quality be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and which include appropriate quantitative or qualitative {

acceptance criteria for determining that important activities have been l satisfactorily accomplished.

Contrary to the above, as of October 26, 1987, activities affecting quality were not, in all cases, prescribed by instructions or procedures which were appropriate to the circumstances and which included appropriate quantitative or qualitative acceptance criteria.

1. Zion Procedure PT-2P, Safety Injection System Backup Check Valve Leak Check - RHR Cold Leg Injection Line, failed to provide for adequate leak testing of valves in that:

(a) Valves 2SI-9012 A through D, valves 2SI-9004 C and D, and valves 2SI-8905 A and B were specified to be leak tested in test configurations in which there was no pressure differential i

across the valve being tested.

l Valves were specified to be tested in series. This practice (b) does not allow for quantifying individual valve leakage.

2. Zion Procedure PT-2M, RHR/SI Cold Leg, SI Hot leg Injection Check Valve l Leak Test, failed to provide for adequate leak testing of certain valves in that: .

(a) Valve leakage was specified to be measured either using inaccurate visual means or using an instrument in a configuration which l would render the instrument incapable of measuring flow. I (b) Test pressure in the leak path was specified to be throttled ,

to 1750 psig prior to measuring the valve leak rate; however,  !

the applied test pressure directed by the procedure (600 psig)  !

would not allow the specified 1750 psig to be reached. j I

8801110352 880104 S PDR ADOCK OSO G

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i Notice of Violation eg 4 jggg (c) Procedure PT-2M did not provide for the valving in of the pressure gauge used to determine whether the check valves were leaking, thereby potentially invalidating any readings taken from this gauge. 1 k

(d) Procedure PT-2M did not provide for relieving the test system pressure before continuing the testing of other valves, thereby invalidating the results of subsequent testing.

(e) Valves were specified to be tested in parallel, which does not provide for quantifying individual valve leakage.

B. 10 CFR Part 50, Appendix B, Criterion XI, as implemented by Commonwealth Edison Company's Quality Assurance Topical Report, CE-1-A, requires, in part, that a test program be established to assure that all testing  !

required to demonstrate that structures, systems, and components will perform satisfactorily in service is identified and performed in accordance with written test procedures.

Contrary to the above, as of October 26, 1987, the licensee's test program failed to assure that all testing required to demonstrate that pressure isolation check valves will perform satisfactorily in service was performed in accordance with written test procedures. The procedure did not provide adequate direction as to when the procedures were required to be performed.

Specifically, during the refueling outage from March 1987 through August 1987 and after the safety injection which occurred on July 29, 1987, check valve leakage testing was not specified nor done to assure that the LPI/RHR check valves were installed correctly and functioning as pressure isolation barriers prior to plant startup.

C. 10 CFR Part 50, Appendix B, Criterion II, as implemented by the Commonwealth Edison Company Quality Assurance Topical Report CE-1-A, requires, in part, that the licensee comply with NRC Safety Guide 33, dated November 1972.

Safety Guide 33 states that the requirements and recommendations in proposed i standard ANS-3.2, " Standard for Administrative Controls for Nuclear Power i Plants," dated November 2, 1972 (issued as ANSI N18.7), provide an adequate basis for complying with the quality assurance program requirements of i Appendix B to 10 CFR Part 50. ANSI-3.2, Section 5.4, requires that each procedure be reviewed periodically to ensure that the procedures in current use provide the best possible instructions to the operators.

Contrary to the above, periodic reviews of test procedures PT-2P, PT-2M, and PT-2N, RHR Hot Leg and Cold Leg Injection Check Valve Leak Check, were not performed from November 1980 through August 1987 to ensure that the best possible instructions were provided to the operators.

D. Technical Specification 6.2.1.G requires that written procedures, including applicable checkoff lists covering surveillance and testing requirements, be implemented by the licensee in its operation of the facility.

A prerequisite of surveillance test procedure PT-2P is that the test be conducted when the RCS pressure is greater than 1800 psig.

'J/,N 4 1988 Notice of Violation -

3-Contrary to the above, on July 29, 1987, a surveillance test prerequisite for procedure PT-2P was not implemented in that the licensee performed the surveillance test when the RCS pressure was only 900 psig.

Collectively, these violations have been categorized as a Severity Level III problem (Supplement I).

Cumulative Civil Penalty - $100,000 (assessed equally among the violations).

Pursuant to the provisions of 10 CFR 2.201, Commonwealth Edison Company (Licensee), is hereby required to submit a written statement or explanation to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, within I 30 days of the date of this Notice. This reply should be clearly marked as a

" Reply to a Notice of Violstion" and should include for each alleged violation:

(1) admission or denial of the alleged violation,-(2) the reasons for_the.

violation if admitted, (3) the corrective steps that have been taken and the results achieved, (4) the corrective steps that will be taken to avoid further violations, and (5) the date when full compliance will be achieved. If an adequate reply is not received within the time specified in this Notice, an order may be issued to show cause why the -license should not be moaified, suspended, or revoked or why such other action as may be proper should not be taken. Consideration may be given to extending the response time for good cause shown. Under the authority of Section 182 of the Act, 42 U.S.C. 2232, this response shall be submitted under oath or affirmation.

Within the same time as provided for the response required above under 10 CFR 2.201, the Licensee may pay the civil penalty by letter to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, with a check, draft, or money order payable to the Treasurer of the United States in the amount of civil penalty proposed above, or may protest imposition of the civil penalty in whole or in part by a written answer addressed to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission. Should the Licensee fail to answer within the time specified, an order imposing the civil penalty will be issued. Should the Licensee elect to file an answer in accordance with 10 CFR 2.205 protesting the civil penalty, in whole or in part, such answer should be clearly marked as an " Answer to a Notice of Violation" and may: (1) deny the violations listed in this Notice in whole or in part,- (2) demonstrate extenuating circumstances, (3) show error in this Notice, or (4) show other reasons why the penalty should not be imposed. In addition to protesting the civil penalty, such answer may request remission or mitigation of the penalty.

In requesting mitigation of the proposed penalty, the five factors addressed in Section V.B of 10 CFR Part 2, Appendix C (1987), should be addressed. Any written answer in accordance with 10 CFR 2.205 should be set forth separately from the statement or explanation in reply pursuant to 10 CFR 2.201, but may incorporate parts of the 10 CFR 2.201 reply _by specific reference (e.g., citing.

page and paragraph numbers) to avoid repetition. The attention of the Licensee is directed to the other provisions of 10 CFR 2.205, regarding the procedure i for imposing a civil penalty. t i

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Notice of Violation 'JAN 4 1989 Upon failure to pay any civil penalty due which subsequently has been determined in accordance with the applicable provisions of 10 CFR 2.205, this matter may be referred to the Attorney General, and the penalty, unless compromised, remitted, or mitigated, may be collected by civil action pursuant to Section 234c of the Act, 42 U.S.C. 2282c.

The responses to the Director, Office of Enforcement, noted above (Reply to a Notice of Violation, letter with payment of civil penalty, and answer to a Notice of Violation) should be addressed to: Director, Office of Enforcement, U.L Nuclear Regulatory Commission, ATTN: Document Centrol Desk, Washington, DC 20555 with a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission, 799 Roosevelt Road, Glen Ellyn, Illinois, 60137, and a copy to the NRC Resident Inspector at Zion.

FOR THE NUCLEAR REGULATORY COMMISSION kfM b ' Mu A. Bert Davis Regional Administrator Dateda)4 Glen Ellyn, Illinois this 4 day of January 1988

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. J OCT 2 91997 J Docket No. 50-i?S Docket No. 50-304 EA 87-211-

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Commonwealth Ecison Company ATTN: Mr. Cordell Reed Vice President Post Office Box 767 Chicago, IL 60690 Gentlemen:

This refers to the special safety inspection conducted by NRC inspectors .q M. M. Holzmer and P. L. Eng of this offi.:e on September 21 through October 26, >

1987, of activities at the Zion Nuclear Generating Station, authorized by .l Licenses No. DPR-39 and No. DPR-48. j The inspection. focused on the testing and operability of pressure isolation-check' valves (PIVs) between the reactor coolant system (RCS) and the low- )

pressure emergency core cooling systems (ECCS) to which the RCS is connected.

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.The enclosed copy of our inspection report identifies specific areas examined during the inspection. .Within these areas, the inspection consisted of a -

selective examination of procedures and. representative records, observations, and interviews ~with personnel.

You will We are releasing this report at this time for your information.

be notified by separate correspondence of our decision regarding enforcement j action based on the findings of this inspection ~ No written response is required until you are notified of any proposed enforcement action.' ,

1 In accordance with 10 CFR 2.7. 0 0 of the Commission's regulations, a copy of 8

this letter, and the enclosure, will be placed in the' NRC Public Document-Room.

We will gladly discuss any questions you have concernin'g this inspection..

Sincerely,-  ;

i osmALmammaic.a.nommw Charles:E. Norelius, Director Division of Reactor Projects

Enclosure:

Inspection Reports No. 50-295/87032(DRP); and No. 50-304/87033(DRP)  :

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Attachment:

Zion Emergency Core Cooling System' Simplified Diagram _. .

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See Attached Distribution fp

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Commonwealth Ediso, h mpany 2 28 15d7 Distribution cc w/ enclosures:

T. J. Maiman, Vice President, PWR Operations D. Butterfield, Nuclear Licensing Manager G. J. Plim1, Station Manager Jan Norris, Project Manager, NRR DCD/DCB (RIDS)

Licensing Fee Management Branch Resident Inspector, RIII Richard Hubbard '

J. W. McCaffrey, Chief, Public Utilities Division Mayor, City of Zion J. Lieberman, OE J. Goldberg, 0GC F. Miraglia, NRR P

e t

. . . _ . . _ _..__.E.__.__.____.l.______.____E_-_m_--a

U.S. NUCLEAR REGULATORY COMMISSION REGION III Reports No. 50-295/87032(DRP); 50-304/87033(DRP)

Docket Nos. 50-295; 50-304 Licenses No. DPR-39; DPR-48 Licensee: Commonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Name: Zion Nuclear Power Station, Units I and 2 Inspection At: Zion, Illinois Inspection Conducted: September 21 through October 26, 1957 Inspectors: M. M. Holzmer P. L. Eng it Jsf -

Approved By. M. Hinds, ' i l o 2 L 87 Reactor Projects Section IA Date Inspection Summary Inspection on September 21 through October 26, 1987 (Reports No. 50-295/87032(DRP);

50-304/87033(DRP))

Areas Inspected: Special, unannounced safety inspection of testing associated with-reactor coolant system (RCS) pressure isolation check valves (PIVs),

Licensee Event Reports (LERs); and related licensing history and associated i licensee practices. l Results: Of the two areas inspected, potential violations of quality assurance '

program requirements as applied to testing of PIVs, a potential violation of Technical Specification requirements to conduct testing in accordance with approved test procedures, and a potential violation of an NRC Order were identified. Together, these violations. indicate a potential breakdown of the licensee's management control system for PIV testing.

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DETAILS

1. Persons Contacted i

1. • G. Plim1, Station Manager

• E. Fuerst, Superintendent, Production

• T. Rieck, Superintendent, Services W. Kurth, Assistant Station Superintendent, Operations

• R. Budowle, Assistant Station Superintendent, Technical Services

• L. Pruett, Unit 1 Operating Engineer R. Cascarano, Technical Staff Supervisor C. Schultz, Regulatory Assurance Administrator

1. L. Holden, Regulatory Assurance Engineer

• J. Ballard, Quality Control Supervisor

• W. Stone, Quality Assurance Supervisor

1. • T. Printz, Assistant Technical Staff Supervisor

• J. Tiemann, Primary Group Leader, Technical Staff

1. • M. Pigon, Engineer, Primary Group W. Reecher, Engineer, Primary Group

• M. Madigan, In-Service Testing Coordinator, Technical Staff

• B. Soares, Engineer, In-Service Testing Group

1. P. LeBlond, Licensing Staff

1. • F. Lentine, PWR Licensing Supervisor

• J. Johnson, Westinghouse Site Representative'

1. J. Yost, Quality Control

1. A. Padleckas, Technical Staff Engineer

1. R. J. Neeley, Quality Assurance Inspector

1. J. Reiss, PWRE Field Engineering Supervisor

• Indicates persons present at exit interview conducted on 0ctober 9, 1987.

1. Indicates persons present at exit interview conducted on October 26, 1987.

2. Pressure Isolation Valve (PIV) Testino (93702)

Background

The Reactor Saf ety Study (RSS), WASH-1400, identified, in a pressurized water reactor (PWR), an intersystem loss of coolant accident (LOCA) which is a significant contributor to public risk from core melt accidents.

The Event.V scenario described in WASH-1400 consists of a LOCA caused by the failure of two check valves in series; the escaping coolant then bypasses containment by subjecting a low pressure system to full. RCS pressure. Event V therefore results in both a LOCA with potential for core melt and a simultaneous breach of containment. The design examined in the RSS~ consisted of two check valves in series as PIVs, although.

other Event V configurations exist.

Zion station has two Westinghouse 4-loop PWRs,. the emergency core cooling systems (ECCS) for which include both a safety injection (SI) system.and a residual heat removal (RHR) system. The design pressures of these systems are 1700 psig and 600 psig, respectively. Overpressurization 2

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of these systems is prever.ted by the use of two series check valves as PIVs, as well as by relief valves, the setpoints of which are designed I to prevent pressure in the low pressure system from exceeding the design I pressure of the piping. There is shared piping between the SI and RHR i systems for the four cold leg injection lines and for two of the four hot l leg injection lines. The PIVs and their descriptions are provided below (see Attachment 1):

Valve No. Description Event V Valve l i 251-9001 8" combined SI/RHR cold leg Yes A-D injection, closest valve to RCS 251-9002 8" RHR cold leg injection, second No A-D valve from RCS j i

25I-9012 2" SI cold leg injection, second Yes I A-D valve from RCS l

2RH-8949 8" combined SI/RHR hot leg Yes A and B injection, closest valve to RCS '

251-8949 2" SI hot leg injection, closest No C and D valve to RCS 251-8905 2" SI hot leg injection, second No A and B valve from RCS 2RH-8736 8" RHR hot leg injection, Yes A and B second valve from RCS 2SI-9004 2" SI hot leg injection, No C and D second valve from RCS Event Chronology February 23, 1980 As a result of WASH-1400 studies, the NRC issued a letter pursuant to 10 CFR 50.54(f) to all light water reactor (LWR) licensees requesting information regarding measures taken to test Event V check valves {

for pressure isolation capability. The letter delineated acceptable test methods for testing "each check valve" and stated that each licensee's  !

. response would aid in the determination of whether I its facility license should be' modified. The letter specifically requested: ,

e a description of the valve configurations e.t each facility, ,

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• a determination of whether Event V valve configurations exist, the type of testing conducted on and the past test history of these valves, and

• a statement of whether plant procedures or modifications are necessary to adequately test the valves.

February 29, 1980 The NRC issued Confirmatory Orders to Zion and Indian Point which imposed short and long term requirements to both licensees; these plants were considered to pose a disproportionate risk to the public because the plants are situated in densely populated regions. The Confirmatory Order included Item A.5, requiring the licensee to conduct testing to assure that the LPI (Low Pressure Injection)/RHR check valves are installed correctly and functioning as pressure isolation barriers prior to plant startup and periodically thereafter.

March 14, 1980 The licensee responded to the February 23, 1980 letter, stating that some valves in the SI er" CHR systems meet 1 the Event V configuration, that sta. ion jrocedures have been revised to perform leak testing ca the first in each set of two check valves once each refueling outage to verify its integrity, and that the valves will be tested every time the RCS is brought to within 100 psig of the maximum possible pressure on the low pressure side of the valves.

March 28, 1980 The licensee responded to Item A.5 of the l February 29, 1980 Confirmatory Order and stated that l changes to station procedures were being prepared to require an LPI/RHR check valve test whenever RCS pressure has decreased to within 100 psig of the RHR system design pressure. ,

April 20, 1981 Confirmatory Orders were issued to various LWRs with specific instructions for testing PIVs and acceptance criteria to be applied for such testing. These Orders were much more specific with respect to Event V valves  ;

than was the February 29, 1980 Zion Confirmatory Order. I i

June 22, 1984 As part of questions generated by review of the i licensee's In-Service Testing (IST) program for pumps and valves, the NRC requested the licensee to identify those valves'which are leak ra+9 tested because they l perform a pressure boundary isolation (PI) function.

The licensee was also asked if a failure of l i

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Valve MOV-SI 8802 (cold leg SI injection header isolation valve) in the closed position during quarterly exercising would render the analyzed flow path for the SI system inoperable.

January 2,1985 The NRC granted interim approval for the licensee's IST program as submitted, effective until December 31, 1985.

January 25, 1985 The licensee responded to the NRC questions on its IST program, ioentified valves that serve a PI function, and stated that the IST program will be revised to reflect PI testing on a refueling outage basis.

The response also stated that failure of.MOV-SI 8802 in the closed position would render the SI cold leg injection path inoperable and that the licensee will revise the IST program to stroke the valve on a cold shutdown frequency.

February 1985 The licensee's implementation of the IST program was inspected. The licensee was cited for lack of administrative procedures governing IST and lack of evaluation and trending of test results. The licensee was also cited for one example of using noncalibrated, nontraceable test equipment (stopwatches) to determine component operability.

June 1986 During performance of PT-2A, " Safety Injection Pump Test," the licensee discovered that the SI pump performance was not consistent with past results. Further investigation by the licensee revealed that the SI pump discharge header was pressurized. Informal, undocumented temperature surveys of the cold leg injection piping revealed that valves 2SI-9012 A and D and 25I-9001 A and D appeared to be leaking. Work requests to repair or replace the subject valves were written. A temporary procedure change to PT-2A was written to provide for depressurizing +he SI pump discharge header for pump test purposes by opening valve 251-8961, a normally locked closed containment isolation valve (CIV).

Some external leakage, as well as' seat leakage, from SI relief valves 251-9030 and 251-9031 was observed.

These valves are located on the discharge piping coming from the "A" and "B" SI pumps, respectively. The relief setpoint for each valve is approximately 1750 psig. RCS unidentified leak rates did not exceed I gpm.

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October 15, 1986 As a result of significant check valve failures at l several plants, INPO SOER 86-03, " Check Valve Failure I or Degradation" was issued. The 50ER Identified RHR and LPI system check valves as potential problems.

March 13, 1987 Generic Letter 87-06, " Periodic Verification of Leak Tight Integrity of Pressure Isolation Valves (PIVs),"

was issued, requesting submittal of a list of all PIVs and a description of testing performed "for each valve" to assure valve integrity as an independent i barrier, including pertinent acceptance criteria.

March 28, 1987 The licensee performed PT-2P, " Safety Injection System Backup Check Valve Leak Check - RHR Cold Leg Injection Line," prior to starting the scheduled Unit 2 refueling outage. PT-2P tests as many as 16 valves simultaneously in series and parallel combinations. Valve leak rates met the procedure acceptance criteria of PT-2P. Consequently, PT-2M and PT-2N, which would have more nearly determined the leak rates of individual valves, were not performed. PT-2M and PT-2N are normally required to be performed only if PT-2P indicates gross leakage, but may be performed at an engineer's discretion.

The test data met the PT-2P acceptance criteria; however, as later discussions will show, the test methodology did not adequately test the valves.

i March 1987 The scheduled Unit 2 refueling outage began. Two check valves in the boron injection lines to the cold legs were replaced (these are not Event V l

valves, since the boron injection lines are not low pressure lines). Parts for repair or replacement of valves 25I-9012 A and D and 251-9001 A and D were not available because they were not' ordered in time-to accommodate the extensive lead-time needed for procurement.

April 6, 1987 The NRC issued Temporary Instruction (TI) 2515/84,

" Verification of Compliance with Order for Modification of License: Primary Coolant System Pressure Isolation (Event V) Valves." Appendix I to this TI identified that Zion h:d received an order prior to April 20, 1981, and was subject to inspection as prescribed by f the TI.

June 11, 1987 The licensee responded to GL 87-06. The Zion response identified PIVs which were leak tested and delineated the acceptance criteria as 5 gpm. The response did not indicate that PIVs were series tested in groups t

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as opposed to individually. The response stated that all potentially leaking valves were " repaired to  ;

prevent overpressurization of the lower pressure system thereby lifting the relief valves."

July 28-29, 1987 A meeting at Zion station took place to resolve differences between NRC reviewers and the licensee about the licensee's second ten year IST program.

The licensee agreed to withdraw relief request VR-25, which would have exempted SI PIVs from leak testing.

Although the valves were included in the IST program, the licensee stated that PIV leak test results were not subject to the trending evaluation of Section XI, because the licensee had not been specifically directed to impose all Section XI requirements to components which they stated were added to the IST program "for tracking purposes only."

July 29, 1987 During performance of PT-2P, approximately 3500 gallons of water were injected into the RCS, as reported in LEF,304/87006. Initial conditions of the test required ,

the RCS pressure to be above 1800 psig. .The actual RCS pressure was 900 psig. Valves 251-9012 A through D and 251-9001 A through D, which were tested in the section just prior to the injection, were lifted off their fully closed seats due to the injection.

July 30, 1987 The licensee performed PT-2P following the injection on July 29, 1987, but omitted Section II of the procedure because RCS temperature exceeded the 450F initial condition for Section II.Section II tests the SI-9001 A through D valves. PT-2M and PT-2N were not performed because the leak rates _ obtained during PT-2P met the acceptance criteria.

August 26, 1987 The licensee was cited for inadequate corrective action taken in response to the 1985 violation for using noncalibrated, nontraceable measuring and test equipment for determining component operability.

September 14-18, An NRC Vendor Branch team inspection,regarding the licensee's response to INPO SOER 86-03 was conducted at Zion, as well as at one plant in each of the other four NRC regi.as. The team leader expressed-concern related to Zion's series testing of PIVs.

September 18, 1987 The licensee and the NRC-resident inspectors held discussions regarding plant operations with Manual CIV 251-8961 open. The licensee felt that 7

leaving 251-8961 open would prevent the continuous SI discharge header pressurization. The intent of the discussions was to determine whether leaving this valve open would cause a regulatory or safety concern.

with respect to containment integrity.

September 21, 1987 The NRC resident inspectors, in coordination with NRC headquarters reviewers, began a detailed review of the licensee's PIV Test Procedures PT-2P and PT-2M.

The review identified several significant test deficiencies. During the week of September 21, the inspectors held discussions with technical staff personnel in which the inspectors expressed concern that several Unit 2 valves did not have valid test results to assure that each valve was performing its PI function and to verify compliance with the February 29, 1980 Confirmatory Order.

September 24, 1987 The licensee radiographer Valves 251-9012 A through D to verify that the valve disks and springs were installed. Informal temperature surveys of cold leg injection piping using a contact pyrometer indicated that 2SI-9012C and 2SI-9001B (two series PIVs in the same SI cold leg discharge line) are leaking.

September 25, 1987 The licensee was informed of the NRC's concerns associated with PIV testing by a conference call between Region III, the resident inspectors, Zion Station and Ceco corporate offices. Issues discussed included PIV testing deficiencies which resulted in '

untested PIVs, operations with CIV 251-8961 open, and test procedures in which 2 MOV-SI 8802 is closed.

The licensee stated that it believed that its test program met regulatory requirements, and that PIV testing was intended only to detect gross leakage.

September 25, 1987 The itcensee administrative 1y took 251-8961 and 151-8961 out of service, pending determination of whether manipulation of 51-8961 is allowed by the Zion Technical Specifications (TS).

September 28, 1987 The NRC informed the licensee that, based on the October 10, 1972 Safety Evaluation Report of the licensee's Final Safety Analysis Report (FSAR),

valve 251-8961 should remain shut, but may be opened periodically for short durations for plant operations or testing. This acceptance was based on missile protection for the SI- test header piping as well as a low usage factor. ,

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i October 2, 1987 The licensee conducted TSSP-74-87 to check leakage l past 251-9001 A through D. The test used 2FI-928, a rotometer, whic? had never been calibrated by the  !

licensee. The resident. inspectors informed Region III l and the licensee that test results obtained when using a non-calibrated test instrument are not acceptable.

October 2, 1987 The licensee rcdiographed valves 251-8905 A and B and 251-9004 C and D.

Unit 2 PIV Testina Concerns

a. PIV Testing and Test Results (1)- PIV testing procedure PT-2M, "RHR/SI Cold Leg, SI Hot Leg Injection Check Valves Leak Check" will not produce the intended results if performed as written. PT-2M was last performed on March 28, 1987, prior to the last Unit 2 outage. The following discrepancies were noted:

• In Sections II and III, check valve leakage flow is estimated by opening a pressure gauge vent valve.and visually determining the flow rate.

• In Section IV, the procedure fails to instruct operators to valve in pressure gauge PI-933 prior to reading the gauge. In the March 28, 1987 test, a pressure of 0 psig was recorded for the upstream side of the Loop B check j valves. Since the procedure did not direct operators to valve in the gauge, it cannot be demonstrated whether the {

l actual pressure was zero, or the gauge was isolated. In )>

the test, this deficiency would produce non-conservative results.

• The procedure does not provide for bleeding off pressure on the upstream side of tested PIVs between successive sections of the test. Consequently, high pressures may persist into the next section, yielding inconclusive test results.

• In Sections II, III, IV and V, operators are required ,

to measure the flow rate after throttling pressure to 1750 psig; however, the applied test pressure is only 650 psig. As a result, leak rates are not' quantified.

(2) PIV testing procedure. PT-2P, " Safety Injection System Backup Check Valve Leak Check - RHR Cold Leg injection Line," will not produce the intended results if'perf6rmed as written.

PT-2P was performed on July 29 and 30, 1987, while the licensee was preparing to place Unit 2 on line following the last refueling outage. The following discrepancies were noted:

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• In Section I of the procedure, the following PIVs are not adequately tested due to a test lineup which a equalizes pressure across the valves: 251-9012 A through D, 251-9004 C and D, and 251-8905 A and B.

• In Section II of the procedure, the following PIVs are not adequately tested due to a test lineup which equalizes pressure across the valves: 251-9002 A through 0 and 2RH-8736 A and B.

• Because of these inadequacies in PT-2P, and because later sections of PT-2P do not repeat tests of these valves, there were no valid test results for several PIVS (251-9012 A through 0, 251-9004 C and D and 251-8905AandB).

PT-2P tests several PIVs in series. This method does not adequately test each of the two valves, but determines the effectiveness of the one valve in the pair which is leaking the least. The ability of the other valve to ,

perform its PI function is indeterminate. l

• Because the July 29,1987, PT-2P initial test conditions werenotmet,the2Asafetyinjectionpum) injected 3500 gallons of refueling water storage tank (RWST) water into the RCS, as documented in LER 304/87006. Thisinjection i invalidated the leak test results for several-PIVs by i stroking 2RH-8949 A and B, 251-9012 A through D, {

251-9001 A through D, and 251-8905 A and B. j (3) As a consequence of these deficiencies, and the fact that only  !

PT-2P was performed at the conclusion of the last Unit 2 outage, the following valves are considered untested:

Valve No. Reason Not Tested Note )

251-9012 PT-2P fails to adequately test 1,2,4 A through D these valves because the test lineup equalizes pressure across the valves (July 30, 1987 test). '

251-9004 PT-2P fails to adequately test .

C and D these valves because the test 1 lineup equalizes pressure across i the' valves (July 30, 1987 test). 1 2SI-9001 Thesafetyinjectionwhichoccurred 2,4 A through D on July 29, 1987, during Section III. o of PT-2P, lifted these valves off their seats, invalidating the. test results,' >

and Section II of PT-2P, which adequately tests these valves, was not subsequently performed (July 30,1987 test).

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251-8905 The safety injection which occurred 3 A and 8 during Section III of PT-2P on July 29, 1987, lifted these valves off their seats, invalidating the test results, and PT-2M, which adequately tests these valves, was not subsequently performed.

Notes:

1. These valves were radiographer on September 24, 1987 (251-9012 A through D), and October 2, 1987 (25I 8905 A and B and 2SI-9004 C and D), and the disks and springs i appeared to be intact.

.i

2. Violates the NRC Confirmatory Order dated February 29, 1980, which required PIVs to be tested each time plant pressure is reduced to within 100 psig of the RHR system design pressure. (Plant pressure was reduced to atmospheric pressure during the Unit 2 refueling.)

3. Is a potential deviation from a March 28, 1980, response to a 10 CFR 50.54f request dated February 23, 1980. ,

4. These valves were leak checked using a non-calibrated flow instrument. The licensee has expanded the list of untested Unit 2 PIVs following the identification of the non-calibrated flow instrument. In addition, the licensee reviewed Unit 1 PIV test results and concluded that, because the Unit I flow instrument was also not calibrated, Unit 1 PIV test results obtained using that instrument were also not valid.

(4) PIV testing requirements imposed on Zion appear to be much less stringent than those imposed on all other licensees (except Indian Point) by orders issued in 1981. Deficiencies in requirements at Zion include:

• Requirements to test - Zion does not rppear to be explicitly j required to test PIVs when they are moved from their fully shut position. In addition, Zion does not appear to have committed, in response to the February 29, 1980 Confirmatory j Order, to test SI PIVs when RCS pressur( is lowered to below i SI system design pressure plus 100 psig, whereas its l response to the February 23, 1980 50.54(f) letter indicates that it does test 51 PIVs when RCS pressure is lowered to j that point. i

• Test methodology - Zion tests as many as 16 PIVs at a time in PT-2P, many of which are in series. Series testing will only reveal the leak rate for the better of two series PIVs.

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The condition of the worse of the two series PIVs is indeterminate. While the NRC's licensing correspondence frequently refers to "each valve" in discussions of PIV testing, the licensee considers that its series tests meet that intent.

• Acceptance criteria - The February 29, 1980 Confi rmatory Order made no mention of a leak rate acceptance criterion.

Zion's procedural acceptance criterion is 5 gpm. Also, the licensee believes that the intent of the February 29, 1980 Confirmatory Order is that only gross leakage identification is required. This position is based on a January 25, 1980 NRC internal memorandum, which the licensee has, which stated that in the short term leakage rates up to the design flow of ECCS relief valves are acceptable. 1981 Orders to other LWR licensees require acceptance criteria of I gpm, unless the increase in leak rate does not exceed prior leakage by an amount that reduces the margin between the most recent measured leakage and 5 gpm by 50%. In that case, leak rates up to 5 gpm are permissible. Leak rates above 5 gpm or increases which reduce the safety margin by more than 50% above 1 gpm are not acceptable, and specific actions are required.

b. Acceptability of Operations With 251-8961 Open PIV testing (PT-2P, 2M and 2N) requires manipulation of a normally locked closed manual containment isolation valve, 251-8961.

251- 8961 is the single CIV on the accumulator test line containment penetration. This valve was also opened on July 28 and September 1, 1987 to perform PT-2A, " Safety Injection Pump Test." The resident inspectors were concerned that opening 251-8961 appeared to violate containment integrity as defined in Technical Specification (TS)

Definition 1.11.

The licensee's FSAR, Section 6, indicates that ECCS. testing during power operations will be performed. Although not explicitly stated, this testing would reasonably include opening 251-8961. In a Safety Evaluation Report (SER) dated October 6, 1972, the NRC approved the licensee's containment isolation design despite the fact that General Design Criteria 53, 56, and 57 were.not met for some containmer,t penetrations. This acceptance was based on penetrations having either missile protectioa for affected piping inside containment, low usage

• factors for the penetrations, or additional valves outside containment which could be closed in the ev?nt of a leak. It therefore appears that the intent of both the licensee and the NRC was that opening valves such as 251-8961 for short periods of time is permissible.

In a telephone conversation between the NRR licensing project manager, hRR reviewers, and the Zion ' resident inspector and his immediate management, it was agreed that for purposes of interpretation, it would be permissible to allow the licensee to open 251-8961 for 12

short durations during operations, since, af ter considering the intent of the FSAR and the SER, the closed missile protected pipe constitutes a barrier as good as that specified in section a.2 of the definition of containment integrity.

The resident inspector informed the licensee that a TS revision is needed to clarify how containment integrity is to be defined as it pertains to " closed systems" inside containment, as in the present case. The licensee agreed to clarify this TS in a future TS change request.

c. Acceptability of Conducting Tests With 2 MOV-SI8802 Shut IE Information Notice (IEN) 87-01 alerted licensees to a potentially significant event, which may occur when valve misalignment hi the ECCS could degrade the system performance. In the examples given, RHR cross-connect valves and discharge valves-(all are motor operated valves [MOVs)) were closed for testing or maintenance, isolating two of four cold leg injection paths from the remaining available RHR pump, while one pump was being tested. For these licensees, ECCS analyses assumed that one RHR pump injected into all four cold legs. Closing cross-connect or discharge MOVs therefore placed the plant in an unanalyzed condition.

While reviewing PT-2A, " Safety Injection Punp Test," the inspectors learned that to perform PT-2A, the licensee sometimes closes 2 MOV-SI8802 (depending on plant conditions), which isolates both SI pumps from all four SI injection paths. This appeared to be similar to the event described in IEN 87-01. During the test, the licensee leaves 2 MOV-SI8802 energized. Per Piping and Instrumentation Drawing (P&ID) M-521, this valve receives an "S" signal to open automatically in the event of an ECCS actuation.

l The inspectors reviewed the. licensee's response to IEN 87-01.

The response stated 'that other valves which are in the RHR system correspond to the valves which were noted in the IEN as having potential for causing degradation of the ECCS'if they are closed.-

The valves, RHR header cross connect valves (2 M3V-RH8716 A through C) and RHR discharge valves (2 MOV-RH8809 A and B), are closed in PT-28, 2P, and 2N. These test procedures (pts) are performed at hot standby or during power operations. These valves also receive an "S" signal to open in the event of an ECCS actuation. The licensee concluded that the IEN did not apply to Zion. The IEN response also stated that Zion's ECCS analysis assumes'that injection occurs in all four cold legs in the event of an accident.

1 While its response to the IEN fails to consider the closure of l

any of these valves for maintenance or due to equipment failure

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(non-surveillance conditions), the licensee is correct in'that 13

closing any of these valves does not render a component, train, system, or subsystem inoperable, because the valves are capable of opening without operator action in the event of an accident.

The licensee is revising pertinent pts to limit the closure of these valves. It will consider either clarifications to the Technical Specifications or guidance to operators by other means to ensure that it is understood that closure of these valves will not be construed to constitute entry into a TS Limiting Condition for Operation.

Safety Significance According to the EG&G review of the Zion Probabilistic Risk Assessment (PRA) (Report No. EGG-EA7304, Centract No. DE-AC07-76ID01570), the-Event V sequence accounts for 81% of the non-seismic public risk.

(Seismic sequences account for 92% of the public risk.) Consequently, ,

PIV integrity is a significant safety issue. The NRC's February 23, 1980 50.54(f) letter noted that the average failure probability of check valves would be reduced significantly by periodic testing or by continuous surveillance of each valve, underscoring the defense in depth design of-having two PIVs in series. The failure of Zion's PIV testing program J

as described above could have led to a condition in which one of the two '

series valves was tested and found to be operable, and the other was not performing its PI function at all.

Root Cause Analysis

• It appeared that the licensee's PIV testing program is only intended to measure gross leakage. This is inconsistent'with NRC Orders to many other licensees, which specify very low acceptance criteria.

This discrepancy appears to have stemmed from a liberal interpretation of the February 23, 1980 letter and the February 29, 1980 Confirmatory Order.

• The licensee's PIV testing program has been unable to test each valve for even gross leakage, as indicated by the procedural deficiencies described above. This problem appears to have resulted from a failure to fully apply the licensee's Quality Assurance Program to testing of safety related PIVs.

• Technical Staff engineers are ei+,her unaware of some regulatory requirements regarding testing procedures, calibrated test equipment, and documentation of test results required by Orders, 1Ss and the licensee's approved Quality Assurance Program, or they do not understand that these requirements apply to their activities.

• PIV testing is tracked under the licensee'.s IST program, but the licensee has stated that, while these valves are included.in its IST program, PIVs are.not subject to all the requirements of the A5ME Section XI Code. The licensee's position is that these valves 14

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'o I

(and others not mentioned in this inspection) are in the IST program for tracking purposes only. Consequently, leak rates are not

's specified or trended for individual valves. Testing responsibility for valve leak testing is fragmented in that testing is conducted by one Technical Staff group and tracked by another Technical Staff group, and results are not evaluated or trended by either group.

Inspector Concerns

• The licensee's response to GL 87-06, dated June 11, 1987, states, "All potentially leaking valves are repaired to prevent overpressurization of the lower pressure system and consequently lifting the relief valves." Although PIV leakage was known to be pressurizing the SI header in mid-1986, the licensee failed to procure replacement valves in time to.make repairs during the March through August 1987 Unit 2 refueling outage. Its response to GL 87-06 also was sufficiently vague as to permit a reasonable agency reviewer to conclude that the Zion PIV test response was acceptable, when, in reality, the program was inadequate.

• Some leak rate quantifications were performed visually by the Technical Staff, but the licensee has not been able to show how engineers performing visual leak rate quantifications have been trained and qualified. In addition, there exists no formal program to demonstrate how these measurements are performed, and that the results obtained conservatively estimate the sizes of leaks.

Corrective Actions The licensee has initiated steps to accurately determine the status of untested Unit 1 and Unit 2 PIVs. Specific actions involve fabrication and installation of calibrated flow measurement instrumentation for determining PIV leakage, procedure revisions, and reviews for improvements in test methodology. Actual testing will be performed as soon as preparations are complete. Radiography of some valves will be reviewed in accordance with approved procedures, and if necessary, additional testing or radiography will be performed to assure that radiographer valves are performing their PI function. A review of visual leak rate estimation practices will be performed.

Enforcement

a. Zion Technical Specification 6.2.1 requires that surveillance tests be conducted in accordance with written procedures. PT-2P, " Safety Injection System Backup Check Valve Leak Check," prerequisites require that the reactor coolant system pressure be greater than 1800 psig.

PerformanceofSurveillanceTestPT-2P,"SafetyInjectionSystem Backup Check Valve Leak Check," on July 29, 1987, with reactor coolant system pressure below that specified in the test prerequisites is a violation of TS 6.2.1. This violation resulted in an injection of 3500 gallons of water into the reactor coolant system.

15

I s

b. 10 CFR 50, Appendix B, Criterion XII, as implemented by Commonwealth Edison Company's NRC-approved Quality Assurance Program, CE-1-A, in Quality Procedures 12-1 and 12-2, requires that instruments used to perform activities affecting quality be controlled, calibrated  ;

and adjusted on a periodic basis to maintain accuracy. Flow -

Instrument 2FI-928A, which was used to perform activities affecting quality on March 28, 1987, in Procedures PT-2P, " Safety Injection System Backup Check Valve Leak Check," and PT-2M, "RHR/SI Cold Leg, SI Hot Leg Injection Check Valves Leak Check," on July 29, 1987, and July 30, 1987, in PT-2P, and on October 2, 1987, in Procedure TSSP-74-87, "SI Cold Leg Check Valve Leak Test," was .

not controlled, calibrated or adjusted on a periodic basis to i maintain accuracy. 1

c. 10 CFR 50, Appendix B, Criterion XI, as implemented by Commonwealth Edison Company's NRC-approved Quality Assurance Program, CE-1-A, in j Quality Procedure 10-53, requires in part that procedures which )

demonstrate that components will perform satisfactorily shall j include appropriate test requirements and acceptance limits and I that the test is performed under suitable conditions. 10 CFR 50, 1 Appendix B, Criterion V, also implemented by CE-1-A, in Quality j Procedure 11-51, requires in part that activities affecting quality j be performed using procedures appropriate to the circumstances and l include appropriate acceptance criteria. On March 28, July 29, and July 30, 1987, the licensee performed Test Procedure PT-2P, J

" Safety Injection System Backup Check Valve Leak Check." The j licensee also performed Test Procedure PT-2M, "RHR/SI Cold Leg, SI Hot Leg Injection Check Valves Leak Check," on March 28, 1987.

These tests do not demonstrate that pressure isolation valves will  !

perform satisfhetorily, do not impose appropriate acceptance criteria  !

and do not assure that tests are conducted under suitable conditions.

Specific examples include:

• PT-2P fails to adequately leak test valves 25I-9012 A through D, 251-9004 C and D and 251-8905 A and B because the test 3 lineup equalizes pressure across the valves.

• PT-2M requires that leakage flow be measured at a throttled test pressure of 1750 psi; however, the applied test pressure is only 600 psi. In addition, one section of the procedure fails to require valving in the pressure gauge used to determine whether check valves are leaking.

• PT-2M and PT-2P do not test valves individually. Valves are either tested in parallel without conservative assignment of- e leak rates to the parallel valves, or valves are tested in series, indicating only that one of the two valves is performing its pressure isolation function.

• There are no program provisions to test the RHR PIVs'when RCS pressure falls to less than or equal to 700 psi,.or to-test the SI PIVs when RCS pressure falls to less than or equal to 1800 psi.

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{ l

+ 3

)

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• There are no program provisions to test RHR or SI PIVs following )

events which cause the valves to move from their fully closed positions. i

d. A Confirmatory Order dated February 29, 1980, required the licensee to conduct testing to assure that the "LPI/RHR check valves are in fact installed correctly and functioning as pressure isolation barriers . . . whenever RCS pressure has decreased to within )'

100 psig of RHR design pressure." In a letter dated March 14, 1980, the licensee responded to the Commission's 10 CFR 50.54f letter dated February 23, 1980, stating that "Once each refueling outage, a leak test is performed on the first check valve [51-9001 A through D] of each cold leg injection line (PT-2M) to verify their integrity. . . [and] both check valves [51-9012 A through D, 51-9001 A through D] of each SI cold leg injection line will be tested every time the primary coolant system (PCS) pressure ~is brought to within~100 psig of the maximum possible pressure on the low pressure side of these check valves." On July 30, 1987, after the RCS pressure had been reduced to atmospheric conditions during refueling, the licensee failed to perform Section II of PT-2P, " Safety Injection System Backup Check Valve Leak Check," I and PT-2M, "RHR/SI Cold Leg, SI Hot Leg Injection Check Valves I Leak Check," such that PIVs 251-9012 A through D and 2SI-9001 A 1 through D were not effectively tested pricr'to unit startup. I Four violations and no deviations were identified. These violations are collectively ccnsidered an Unresolved Item pending NRC review for escalated i

enforcement (295/87032-01; 304/87033-01). l

3. Licensee Event Reports (LERs) Followup (92700)

Through direct observations, discussions with licensee personnel, and review of records, the following event report was' reviewed to determine that deportability requirements were fulfilled, whether ,

immediate corrective action was accomplished, and whether corrective actions to prevent recurrence had been accomplished in accordace with Technical Specifications. The LER listed below is considered closed:

Unit 2 LER No. DESCRIPTION 87-006 Inadvertent Injection from Safety Injection to the Reactor Coolant System During Periodic Check Valve Leak Testing i This LER was reviewed in connection with the PIV testing inspection described in Paragraph 2. Failure to reet test procedure initial conditions was noted to be in violation of TS 6.2.1.

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No other violations or deviations were identified.

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4. Licensing History and Associated Licensee Practices (92703)

a. On February 23, 1980, the NRC issues a 10 CFR 50.54(f) letter to all LWR licensees, identifying concerns related to Event V valves and requesting the following information:

• Describe the valve configuration at each plant and indicate whether Event V configurations exist within the Class I boundary of the high pressure piping connecting Primary Coolant System (PCS) piping to low pressure systems, e.g., two check valves in series, or two check valves in series with an MOV.

• For those Event V configurations at the plant, indicate whether continuous surveillance or periodic tests are be;ng accomplished to ensure integrity. Also indicate whethe.r 1 testing had revealed any valves lacking integrity.

• Indicate whether plant procedure revisions or plant modifications are needed to increase reliability.

The 50.54(f) letter indicated that acceptable methods to assure  !

component integrity included continuous pressure monitoring on the  !

low pressure side of each check valve and periodic testing of each valve every time the plant is shutdown and each time either check valve (of a series pair) is moved from its fully closed position.

The staff expected typical licensee responses to the 50.54(f) letter to specifically identify Event V valves by number, to describe their configuration and test frequency, and to address test methods used to determine individual valve leakage. It was also. thought that i licensees would include past valve leakage. testing history and j associated test acceptance criteria if used. Responses were subse- 1 quently forwarded to Franklin Research for a technical evaluation, I which if appropriate was used as the basis for a Safety Evaluation l Report (SER). An SER was then attached to each Confirmatory Order .

issued to those plants whose Technical Specifications were amended I to explicitly require individual PIV testing. l i

On March 14, 1980, the licensee responded to the 50.54(f) letter and I identified the RHR hot leg injection path and the SI cold leg injection path as Event V configurations. The licensee also stated ,

the following: l l

Cace each refueling outage, a leak test is performed on the first check valve [ closest to the RCS] of each cold leg injection line (PT-2M) to verify their integrity. The results of this test indicate that the check valves do not leak or lack-integrity. Currently, no tests are performed to verify the integrity of the second check valve of each SI cold leg injection line or either check valve in the RHR hot leg injection line.

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n a

.O In addition, plant procedures at Zion Station have been revised as follows:

1. Both check valves of each SI cold leg injection line will be tested every time the primary coolant system (PCS) pressure is brought to within 100 psig of the maximum possible pressure on the low pressure side of these check valves.

2. Both check valves of each RHR hot leg injection line will be tested every time the PCS pressure is brought to within 100 psig of the maximum possible pressure on the low pressure side of these check valves.

In regard to the discussion above, the inspectors noted the following:

(1) The licensee's check valve tests do not test each valve separately.

(2) The licensee's response to the 50.54(f) letter did not address testing each valve of a series pair each time a valve is' moved from its fully closed position, and the licensee currently does not test valves following actuation.

(3) There is no specific operating constraint in place to ensure that the first check valve of each cold leg injection line is tested during a refueling outage prior to reactor startup. In ,

addition, the procedure currently used to test these valves i does not test them individually and was found to be invalid during a recent inspection.

(4) The licensee's implemented check valve tests include no requirements to the RHR system PIVs when RCS pressure falls to less than or equal to 700 psi (100 psi over RHR system design pressure) or to test SI system PIVs when SI pressure falls to less than or equal to 1800 psi (100 psi over SI system design pressure). The licensee requires PIV testing only in GOP-0,  !

" Plant Startup Documentation Requirements," at the discretion l of the operating engineer prior to leaving hot shutdown.

b. By Confirmatory Order dated February 29, 1980, the licensee was directed to " conduct testing to assure that the LPI/RHR check _

valves are in fact installed correctly and functioning as pressure  ;

barriers when the plant is at pressure and producing power, ,

Verification. . .shall be performed. . .whenever RCS pressure has i decreased to within 100 psig of RHR system design pressure." l 1

By letter dated March 28, 1980, the licensee stated that no '

immediate actions were required of the station; however, '.' changes to l Zion. operating procedures and various periodic tests (pts) are being i 1

l 19

__.________..-m.._..--..-.__ _ --

b

.o prepared which will require a LPI/RHR check valve test whenever RCS pressure has decreased to within 100 psig of RHR system design pressure. These changes will be implemented prior to plant startup 1 following such an RCS pressure decrease."

As stated in paragraph a above, the licensee has no requirements to test check valves when RCS pressure decreases to within 100 psi of' RHR system design pressure.

c. On March 13, 1987, the Commission issued Generic Letter (GL) 87-06, which requested all operating license holders to submit a list of all pressure isolation valves, including the Event V valves, and to describe for each valve the periodic tests or other measures 1 performed to assure the integrity of the valve as an independent barrier at the reactor coolant pressure boundary (RCPB), along with the acceptance criteria for leakage, if any, and associated operational limits.

The staff expected information specific enough in nature to determine whether verification of the leak tight integrity of each PIV as an independent barrier against abnormal leakage, rapidly i propagating failura and gross rupture of the RCS, was being performed. The response was expected to include a list of each individual PIV, the specific test which tests each valve individually, the test frequency imposed and the associated ,

individual valve acceptance criteria. Operational constraints associated with PIVs were also to be addressed in the licensee response.

By letter dated June 11, 1987, the licensee responded to the GL by providing a list of PIVs, including the Event V valves and the pts in which they are tested. The licensee also stated that:

The above valves are leak tested by monitoring flow or pressure -

buildup on the lower side of the PIVs. The acceptance criteria for leakage of PIVs is to be below 5 gpm with exception of MOV-RH8701 and MOV-RH8702. Suction pressure of RHR pumps or less than 200 psig indicates that valves MOV-RH8701 and MOV-RH8702 have acceptable seat leakage in series per PT-2J.

PT-2M and PT-2N are performed if the leakage of valves tested in PT-2P exceeds 5 gpm, to identify the source of leakage. All potentially leaking valves are repaired to prevent overpressure- I zation of the lower pressure system and consequently lifting the relief valves. The leak rate test results are documented in Station Procedure TSS 15.5.20V-8, ISI Valve Surveillance.

In regard to the discussion above, the inspectors note the following:

i (1) The procedure specified as testing the majority of identified PIVs does not provide a valid test for eight of the ' valves-listed, and those valves which~are validly tested are not 20 9

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e a

.o tested individually. Also, PT-2M and PT-2N as currently written do not provide a viable method for. identifying the individual valve which is leaking or for quantification of_the valve leakage.

(2) Zion station currently has evidence that at least two PIVs are leaking at a rate which is sufficient to lift the relief valves on the Unit 2 safety injection pump discharge piping; the relief valves are in fact preventing overpressurization of the non-RCS pressure rated piping. This condition has existed since mid-1986 and was identified prior to the last refueling outage on Unit 2.

(3) The stated leakage acceptance criterion is 5 gpm. The test methodology employed does not provide a viable means of determining actual leak rates, and for those portions of the test in which a valid leak rate can be determined, calibrated <

test equipment is not'used.

Clarification of the licensee's interpretation of PIV testing requirements i as specified in NRC correspondence and determination of how the current '

test program ensures regulatory compliance for PIVs are considered to be an Unresolved Item (295/87032-02; 304/87033-02)

5. Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of noncompliance or deviations. Unresolved Items disclosed during this inspection art discussed in-Paragraphs 2 and 4.

6. Exit Interview (30703)

The inspectors met with licensee representatives (denoted in Paragraph 1) throughout the inspection period and at the conclusion of the inspection conducted on October 8, 1987, to summtrize the scope and findings of the inspection activities. The licensee acknowledged the inspectors' comments.

The inspectors also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspectors during the inspection. The licensee did not identify any such documents or processes as proprietary.

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